CSDR - SDR: The mandatory buy-in is postponed to November 2025


Since June 2022*, CSDR allowed the coexistence of different dates for the implementation of settlement disciplines (SDR). Specifically, it offered the possibility of a delayed starting date for the buy-in obligation (MBI)**. The date had yet to be set: it has now been established.

The Delegated Regulation 2022/1930 amending the Delegated Act 2018/1229 has just been published in the Official Journal of the European Union: the obligation to trigger a buy-in in the event of an aged failing settlement will enter into force on 2 November 2025 (instead of  February 1st, 2022 as originally required). This deadline should allow the MBI version envisaged by the European Commission under CSDR Refit1 to override the original version before it enters into force.

Remember that the settlement disciplines which have been active since February 2022 are:

  • the application of penalties by the CSDs2 on any instruction not fully settled on the agreed settlement date until its settlement or cancellation;

  • confirmation / allocation requirements on the day the transaction is executed.

* Read our Flash News: ESMA's proposal for a 3-year deferral of mandatory buy-in
**MBI: Mandatory Buy-In
1 Read our Flash News: CSDR Refit: The European Commission formalises proposals for amendments | 
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CSD: Central Securities Depository